Dear American Recovery and Reinvestment Act Subrecipients:
This letter is to provide information on and recommend next steps to meet the reporting requirements imposed as a condition of receiving American Recovery and Reinvestment Act (ARRA) of 2009 funds. Although a number of questions still remain related to the reporting requirements, I think it is imperative to share the information we have, so you may begin preparations to submit the required data. This letter focuses specifically on quarterly reports required by ARRA Section 1512.
ARRA subrecipients include school districts, county offices if education, charter schools, school food authorities, child development administrators, and Special Education Local Plan Areas.
On February 17, 2009, President Barack Obama signed the ARRA of 2009 into law. On a national level, $100 billion over a twoyear period is available for education reform. We estimate that California will receive nearly $8 billion in ARRA funds for prekindergarten to grade twelve education.
To date, the California Department of Education (CDE) has released $3.2 billion, including State Fiscal Stabilization Funds (SFSF) ($2.5 billion), Title I, Part A ($450 million), Individuals with Disabilities Education Act (IDEA) ($269 million), McKinney- Vento Homeless Assistance funds ($13.8 million), and Nutrition Equipment Grants ($12.8 million) to California’s public education system under the ARRA. The CDE expects to release Enhancing Education Through Technology (EETT) and Child Care and Development Fund (CCDF) grants in the near future.
The ARRA is clear that every dollar spent must be subject to unprecedented levels of transparency and accountability. To achieve this goal, the ARRA requires extensive reporting by entities receiving ARRA funding. Some reporting requirements apply to all ARRA funds, and some reporting requirements apply to specific programs. This letter addresses quarterly reporting under ARRA Section 1512, which applies to all entities receiving ARRA funds. Required reporting includes such matters as the number of jobs created and retained and the status of the project funded.
In accordance with the guidance on ARRA Section 1512 issued by the federal Office of Management and Budget (OMB), data on the use of ARRA funds by recipients (i.e., the state) and subrecipients (i.e., local educational agencies [LEAs] and other entities receiving funds through the state) are due to the federal government no later than the 10th day after the end of each calendar quarter. The first reports will be due to the federal government on October 10, 2009, and will cover the period from the grant award date through September 30, 2009. For the CDE to meet the federal reporting deadline, subrecipients will have to submit their data to the CDE in late September. We will confirm the exact due date soon.
The CDE is constructing a Web-based data reporting system to collect information for each grant from subrecipients to comply with ARRA Section 1512 reporting requirements. We anticipate that the data system will be available for limited testing in early September and open to subrecipients later in September so subrecipients may input data in time to accommodate CDE review before the federal reporting deadline.
At this time, the CDE intends to follow the same procedures for password distribution to subrecipients that we used for LEAs in the SFSF application process. Passwords will be sent to each subrecipient by e-mail. Child development agencies will use their Contract and Tracking System (CATS) user ID and password to obtain access to the data reporting system.
Data elements to be collected from each subrecipient, for each grant, include (1) data that must be reported to the federal government at the subrecipient level (for example, the name of the subrecipient and the amount of each subaward) and (2) data that the CDE needs to collect from subrecipients to properly report at the recipient (state) level (for example, the number of jobs retained or created).
Some of the data elements that subrecipients are required to submit may be more challenging and therefore may require some additional preparation or forethought on the part of the subrecipient. The more challenging data elements include:
Data elements required for subrecipient-level reporting:
Data elements required from subrecipients to be aggregated for recipient-level reporting:
For ease of reporting, the CDE will preload as much data as possible, including the subrecipient’s name, location and contact, and
grant award amounts. We also intend to provide drop-down or check boxes, to the extent possible, to simplify data entry.
We note that the OMB requirements may change in future reporting periods and we may change our data reporting system to accommodate those changes.
In anticipation of the upcoming reporting period, we recommend that all LEAs and other subrecipients receiving ARRA funding through the CDE immediately do the following:
As I previously mentioned, many questions still remain about the reporting requirements. The ED plans to release additional guidance and tip sheets to assist ARRA grant recipients and subrecipients in complying with ARRA Section 1512 data reporting requirements. As we receive additional information from the federal government about ARRA Section 1512 requirements—and about program specific reporting—we will share it with you. We will continue to keep you apprised of developments concerning ARRA implementation through the listserv and on the CDE ARRA Web page at http://www.cde.ca.gov/ar/. I will also issue a followup communication with more detailed information on the data reporting elements prior to the time that subrecipients must submit their data.
If you have any questions regarding ARRA reporting, please contact the Fiscal Policy Division by phone at 916-319-0658 or by e-mail at firstname.lastname@example.org. You may also contact Linda Hakala, Education Fiscal Services Consultant, Fiscal Policy Division, at 916-319-0658.